Brownfield priorities for a new Government

BB asked leading figures what the new Government's priorities for brownfield policy should be.

31 May 2015

The Conservative election
manifesto promised to prioritize brownfield development in England. We asked
leading figures what the new Government’s priorities for brownfield policy
should be.

British Land Reclamation Society chair Andy Moffat

Future policy which relates
to brownfield land should recognize both the opportunities and risks this type
of land presents.

In an urban context,
brownfield land often occupies significant space amidst other development, and
thus provides opportunity to inject new life into the built environment.

On
even moderately sized sites, this should now include space for green
infrastructure and for sustainable drainage. Brownfield land development should
therefore be considered in a rigorous spatial planning context, taking account
of the needs of, and prospects for, enhancing the community and neighbourhood
as well as providing new housing.

Brownfield policy should
support high standards of development commensurate with modern interpretation
of the sustainable development principle.

Brownfield regeneration must be both forward looking, whilst fully
engaging with existing local community views.

The risk of chemical
contamination in brownfield land is, however, significant, especially if
previously used for industry.

Current
legislation and regulation relating to the identification and treatment of
contaminated land, particularly Part 2A of the Environmental Protection Act
1990, is inadequate and should be thoroughly revised.

Planning authorities also
require more support so that they can exercise their responsibilities
effectively.

The land reclamation sector
has made a real contribution to the regeneration of urban landscapes and
communities over many decades.

It has evolved to embrace the wide range of
professions involved in regeneration and there is almost certainly a greater
understanding of technical opportunities in the private rather than public
sector.

Central and local government should thus provide greater leadership in
promoting land reclamation. They should continue to support organisations such
as the Land Trust in order that
cleaned-up brownfield land is managed well after reclamation.

CPRE will be pressing the new
Government to implement three key pledges that appeared in the Conservative
manifesto: (i) to prioritize brownfield development, (ii) to protect the green
belt and (iii) to require local authorities to have a register of available
brownfield land.

CPRE believes that the National Planning Policy Framework will
need to be changed quickly if the Conservative pledges on brownfield development
and the green belt are to be realised.

Since the NPPF came into force in 2012, developers have too often been
allowed to build what they like, where they like.

In places such as North East
Lincolnshire and Salford, local policies to prioritise brownfield sites have
been overruled by planning inspectors. Conversely, in Leeds and Newcastle,
little or nothing has been done to rein in local authorities that have been
keen to promote large scale releases of green belt even when plenty of
brownfield sites are available.

The commitment to introduce a
brownfield register indicates that the proposals consulted on in early 2015, in
direct response to CPRE’s 2014 From Wasted Space to Living Spaces report,
will be enacted. This is welcome.

But for a register to be successful, the
Government needs to call on local authorities to provide information on an
annual basis and in a consistent format.

Also, brownfield land with obstacles
to development such as contamination should be identified, as well as easily
developable sites.

A final area to watch will be
the controversial pledge to extend the Right to Buy policy to housing
association tenants.

The proceeds will be used to create a new £1bn brownfield
fund.

CPRE welcomes more funding for bringing brownfield sites forward, but a
key issue is whether sufficient affordable housing will be delivered to replace
the homes lost in Right to Buy sales.

Environmental health professionals
have long been involved in regeneration and it’s only natural that the CIEH
believes in “brownfield first”.

It makes sense in so many ways – in making
use of existing infrastructure, replacing eyesores and dereliction, showing
confidence in local people and services and minimising transport needs.

In
fact, it’s such common sense that minimising calls on previously undeveloped
land is almost just a bonus.

It doesn’t, of course, mean
“brownfield always”; brownfield sites aren’t all the same and may not be
suitable for particular reuses, nor will they necessarily be in the right
places.

Sometimes they will have an overriding value left undeveloped;
nevertheless we think there should be good reasons not to redevelop
them, and to do so preferentially and, in principle, support the application of
a sequential test.

On the face of it, so does the new Government, yet
things may not be all they seem; house builders’ share prices didn’t jump on
the election result for nothing

Such a process needs to be
genuine, and ultimately for the public good in pursuit of a more rounded
understanding of sustainable development than we enjoy now.

That means it must
not be set up to fail by an over-restrictive definition of “brownfield” and
contaminated sites (of which there will be many) should not be excluded, in particular
when other avenues to bring them back into use have been shut off.

If public
subsidy is needed to remediate them, so be it, but that should come from a more
realistic and equitable source than the sale of council houses.

If surplus public
land must be seized by new land commissions – though better would be a renewed
trust in planning - there is no reason why fallow private land should not be
thrown into the mix too and local authorities must retain full control over
standards in any event.

Environmental Industries Commission executive director
Matthew Farrow

The Conservative manifesto
was light on environmental pledges – air quality, for example was dismissed
with a throw-away line about “doing even more”.

But one green issue did make a
more meaningful appearance – a commitment to boost house building on brownfield
sites with a £1bn fund to match.

This is welcome but, given
it’s been estimated we will need to find an additional 7m hectares of useable
land to meet future housing and food needs, we need a much more comprehensive
brownfield strategy.

This must start with
promotion of contaminated land or brownfield sites as a resource rather than a
problem so recognition that clean-up is good not just for the environment but
releases more building land.

This then ties into a more general “brownfield
first” approach.

Fiscal incentives also need
revisiting. Existing incentives such as Land Remediation Relief need to be
extended, by raising the rate of relief and/or widening the eligibility.

There
is also a case for targeted incentives for the more deprived areas of northern
towns and cities.

In general we need smart planning and development objectives
and legislation, driving development where it is needed rather than where
developers can make more profit by reducing risk.

For example planning
incentives to promote house building of smaller units in urban areas where
people need to live to access jobs with reduced travel - this will undoubtedly
mean the reuse of more brownfield sites.

Skills also matter - the
construction sector quality programme (“right card for the job”) should be
supported and training and qualification programmes already in place promoted.

A last issue, not exclusive
to brownfield but important nonetheless, is radon – where Public Health England’s work on radon awareness and management
programme needs a boost.

EPUK is supportive of
proposals to prioritise the development of brownfield land if it helps reduce
greenfield sprawl and accelerates the management of the contamination sometimes
associated with brownfield sites.

We note that the new Conservative
manifesto has proposed that brownfield land would be used “as much as
possible”.
The Conservatives have pledged to build 200,000 starter homes on brownfield
land.

One of the temptations of having housing targets is to squeeze in as many
homes as possible on a given parcel of land without any attempt at creating a sense of place.

It wasn’t long ago that
housing densities were the obsession – near where I live is a new housing
estate nearing completion but begun in the mid-2000s.

It is noticeable how
every public space is occupied by parked cars, there is no place for refuse
bins which have to live in front of houses, and weeds abound, growing between
the sections of ubiquitous block paving.

Even after a short space of time the
place is looking neglected and tatty. Perhaps all development master planners
should be made to revisit their creations after five years and again after 10
to see how they have fared and learn from this.

The drive to provide additional housing must be mindful of the wider impacts on
the environment such as deterioration in air quality through increased road
vehicles, waste disposal/recycling and demands on scarce natural resources like
water.

We note that some brownfield sites are contaminated and there will be instances
where land condition is so poor that considerable work will be needed to bring
these sites into a condition where development is feasible.

The amount of
up-front investment is considerable and without a readily available programme
of public funding for this aspect it’s hard to see how these sites will move
forward.

Planning Officers’ Society president David Evans

Making the most effective use
of previously developed land which is not of high environmental value is a core
principle of national planning policy.

The Planning Officers' Society,
which is the voice of public sector planners, believes that this is best
achieved through local planning authorities working with their local
communities in preparing local plans and determining planning applications.

This locally determined place shaping work is key to the creation of successful
mixed use communities properly integrated into the locality with the necessary
infrastructure.

This includes providing not just homes but also local jobs,
community facilities, affordable housing, transport facilities and greenspace.

As Greg Clark said in November 2011: “When people know that they will
get proper support to cope with the demands of new development, when they have
a proper say over what new homes will look like and when they can influence
where those homes go, they have reasons to say ‘yes to growth’”.

The Society is concerned that the proposals to
introduce local development orders to relax planning controls at a national
level will by-pass local community involvement and undermine the creation of
sustainable mixed use places.

The Society believes that decisions on whether or
not a LDO is an appropriate solution should be taken locally through the
democratic process following community engagement.

The Government's desire to
speed up the delivery of affordable housing is welcomed but the Society
believes that local community based decision making is the right way forward.